In the Court of Chancery of the State of Delaware
EFiled: Apr 28 2020 03:30PM EDT Transaction ID 65604938 Case No. 2020-0305-PAF IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE RAYMOND EUGENIO, Derivatively on Behalf of Nominal Defendant, LABORATORY CORPORATION OF C.A. No. 2020-0305-PAF AMERICA HOLDINGS, Plaintiff, vs. LANCE V. BERBERIAN, GLENN A. EISENBERG, ADAM H. SCHECHTER, KERRII B. ANDERSON, JEAN-LUC BÉLINGARD, JEFFREY DAVIS, D. GARY GILLILAND, M.D., PH.D., DAVID P. KING, GARHENG KONG, M.D., PH.D., PETER M. NEUPERT, RICHELLE P. PARHAM, and R. SANDERS WILLIAMS, M.D., Defendants, and LABORATORY CORPORATION OF AMERICA HOLDINGS, Nominal Defendant. VERIFIED SHAREHOLDER DERIVATIVE COMPLAINT Plaintiff Raymond Eugenio (“Plaintiff”), by and through his undersigned attorneys, submits this Verified Shareholder Derivative Complaint (the “Complaint”) against defendants named herein. Plaintiff alleges the following based upon information and belief, except as to those allegations concerning Plaintiff, which are alleged upon personal knowledge. Plaintiff’s information and belief is based upon, among other things, the investigation conducted by and under the supervision of his counsel which included, among other things: (a) a review and analysis of regulatory filings filed by Laboratory Corporation of America Holdings (“LabCorp” or the “Company”) with the United States Securities and Exchange Commission (“SEC”); (b) documents produced by LabCorp pursuant to 8 Del. C. § 220; (c) a review and analysis of press releases and media reports issued and disseminated by LabCorp; (d) a review of other publicly available information concerning LabCorp, including articles in the news media and analyst reports; (e) complaints and related materials in litigation commenced against some or all of the Individual Defendants (defined below) and/or the Company; and (f) applicable rules and regulations.
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